Privacy policy

 

Version 2 21-5-18

  1. Introduction

1.1    We are committed to safeguarding the privacy of our website visitors and service users.

1.2    This policy applies where we are acting as a data controller with respect to the personal data of our website visitors and service users; in other words, where we determine the purposes and means of the processing of that personal data.

1.3    We use cookies on our websites. Insofar as those cookies are not strictly necessary for the provision of our websites, we will ask you to consent to our use of cookies when you first visit our websites.

1.4    In this policy:

"we", "us" and “our” refer to Ceeda Research Limited

“you” and “your” refer to our website users and service users.

“Ceeda Survey Service” refers to questionnaires and survey tools we supply to our clients.

“Ceeda Survey Service Subscription” refers to an agreement to supply the Ceeda Survey Service.

“Ceeda Survey System” refers to the survey platform used to deliver the Ceeda Survey Service.

“Survey Respondent’ refers to an individual completing a survey administered on the Ceeda Survey   System.   

  1. How we use your personal data

2.1    In this Section 2 we have set out:

(a)    the general categories of personal data that we may process;

(b)    the purposes for which we may process personal data; and

(c)    the legal bases of the processing.

2.2    We may process data about your use of our website and services ("usage data"). Ceeda Research Limited is the data controller. The usage data may include your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your service use. The source of the usage data is our analytics tracking system. This usage data may be processed for the purposes of analysing the use of the website and services. The legal basis for this processing is consent.

2.3    We may process information contained in any enquiry you submit to us regarding goods and/or services ("enquiry data"). Ceeda Research Limited is the data controller. The enquiry data may be processed for the purposes of offering, marketing and selling relevant goods and/or services to you. The legal basis for this processing is consent.

2.4    We may process information relating to our customer relationships, including customer contact information ("customer relationship data"). Ceeda Research Limited is the data controller. The customer relationship data may include your name, your employer, your job title or role, your contact details, and information contained in communications between us and you or your employer. The source of the customer relationship data is you, your employer or published information.  The customer relationship data may be processed for the purposes of managing our relationships with customers, communicating with customers, keeping records of those communications and promoting our products and services to customers. The legal basis for this processing our legitimate interests, namely the proper management of our customer relationships.

2.5    We may process information relating to transactions, including purchases of goods and services, that you enter into with us and/or through our website ("transaction data"). The transaction data includes your contact details, your card or bank details and the transaction details. The transaction data may be processed for the purpose of supplying the purchased goods and services and keeping proper records of those transactions. The legal basis for this processing is the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract and our legitimate interests, namely the proper administration of our website and business.

2.6    We may process information that you provide to us for the purpose of subscribing to our newsletters. ("notification data"). Ceeda Research Limited is the data controller. The notification data may be processed for the purposes of sending you the relevant notifications information and/or newsletters as per your stated preferences. The legal basis for this processing is consent.

2.7    We may process information contained in or relating to any communication that you send to us ("correspondence data"). Ceeda Research Limited is the data controller. The correspondence data may include the communication content and metadata associated with the communication. Our website will generate the metadata associated with communications made using the website contact forms. The correspondence data may be processed for the purposes of communicating with you and record-keeping. The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business and communications with users.

2.7   We may process personal data uploaded by you to the Ceeda Survey System for the purposes of issuing survey invitations at your instruction (“Survey sample”). Ceeda Research Limited is the data processor. Personal data you upload to the Ceeda Survey System is managed by you as data controller and can be edited and managed by you in the ‘Manage Recipient’ areas of the Ceeda Survey System. The legal basis for this processing is our legitimate interests, in fulfilling our service obligations to you.   

2.8    We may process personal data submitted by individuals taking part in surveys on the Ceeda Survey System (“Survey data”). Ceeda Research Limited is defined as a joint data controller with you, the user of the Ceeda Survey Service, each having control over the purposes and means of the processing. The legal basis for this processing is consent, which is collected at the time of survey participation.     

2.9    We may process any of your personal data identified in this policy where necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure. The legal basis for this processing is our legitimate interests, namely the protection and assertion of our legal rights, your legal rights and the legal rights of others.

2.10    In addition to the specific purposes for which we may process your personal data set out in this Section 2, we may also process any of your personal data where such processing is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.

2.11  Please do not supply any other person's personal data to us, unless we prompt you to do so.

  1. Providing your personal data to others

3.1    Financial transactions relating to our website and services are handled by our payment services providers, Paypal and First Capital Cashflow Limited. We will share transaction data with our payment services provider only to the extent necessary for the purposes of processing your payments, refunding such payments and dealing with complaints and queries relating to such payments and refunds. We do not permit these third-party service providers to use the personal information that we share with them for their marketing purposes or for any other purpose than in connection with the services they provide to us.

3.2   We may share information, including personal information, with trusted third-party service providers, that we use to provide hosting for and maintenance of our websites, customer relationship management, accounting and office applications.  We do not permit our third-party service providers to use the personal information that we share with them for their marketing purposes or for any other purpose than in connection with the services they provide to us.

3.3   We share the personal data you upload to the Ceeda Survey System with a third-party mail service provider, for the purposes of issuing email survey invitations at your instruction.  We do not permit this third-party service provider to use the personal information that we share with them for their marketing purposes or for any other purpose than in connection with the services they provide to us.

3.4    In addition to the specific disclosures of personal data set out in this Section 3, we may disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person. We may also disclose your personal data where such disclosure is necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.

  1. International transfers of your personal data

4.1    In this Section 4, we provide information about the circumstances in which your personal data may be transferred to countries outside the European Economic Area (EEA).

4.2    We make use of Microsoft services with headquarters in the United States. Microsoft uses the Standard Contractual Clauses (also known as the Model Clauses) as a basis for transfer of data for its enterprise online services. The Standard Contractual Clauses are standard terms provided by the European Commission that can be used to transfer data outside the European Economic Area in a compliant manner. The Article 29 Working Party has specifically found Microsoft’s implementation of the Standard Contractual Clauses are compliant.

Retaining and deleting personal data

5.1    This Section 5 sets out our data retention policies and procedure, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal data.

5.2    Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.

5.3    We will retain your personal data as follows:

  1. Personal data about your use of our website ("usage data") will be retained for a period of 12 months;
  2. Personal data relating to transactions, including purchases of goods and services, that you enter into with us and/or through our website ("transaction data") will be held for a minimum of 7 years following delivery of said goods and services, unless otherwise stated in the terms and conditions of supply;
  3. Personal data that you provide to us for the purpose of subscribing to our newsletters ("notification data") will be held for a minimum period of 12 months at which time we will contact you to review and act upon your consent preferences;
  4. Personal data relating to any communication that you send to us ("correspondence data") will be held for a minimum period of 12 months or as required to implement our legitimate interests, namely the proper administration of our business and communication with you.
  5. Personal data relating to our customer relationships ("customer relationship data") will be held for 12 months or as required to implement our legitimate interests, namely the proper administration of our business and communication with you.
  6. Personal data relating to any enquiry that you send to us ("enquiry data") will be held for a minimum period of 12 months or as required to implement our legitimate interests, namely the proper administration of our business and communication with you.
  7. Personal data that you upload to the Ceeda Survey System (“survey sample”) is held at your discretion as data controller, in line with your privacy policy. We act in line with your requests to process this data. On termination of a Ceeda Survey Service Subscription we will securely delete personal data uploaded by you to the Ceeda Survey System.
  8. Personal data submitted by survey respondents in surveys administered by the Ceeda Survey System (“survey data”) will be retained for 13-months from the date of submission to manage quality assurance and survey incentives. Personal data identifying natural living persons will then be securely destroyed, at which point the remaining survey data is rendered outside the scope of data protection legislation.

 

5.4    Notwithstanding the other provisions of this Section 5, we may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.

  1. Amendments

6.1    We may update this policy from time to time by publishing a new version on our website.

6.2    You should check this page occasionally to ensure you are happy with any changes to this policy.

6.3    We will notify you of significant changes to this policy by email.

  1. Your rights

7.1    In this Section 7, we have summarised the rights that you have under data protection law. Some of the rights are complex, and not all of the details have been included in our summaries. Accordingly, you should read the relevant laws and guidance from the regulatory authorities for a full explanation of these rights.

7.2    Your principal rights under data protection law are:

(a)    the right to access;

(b)    the right to rectification;

(c)    the right to erasure;

(d)    the right to restrict processing;

(e)    the right to object to processing;

(f)    the right to data portability;

(g)    the right to complain to a supervisory authority; and

(h)    the right to withdraw consent.

7.3    You have the right to confirmation as to whether or not we process your personal data and, where we do, access to the personal data, together with certain additional information. That additional information includes details of the purposes of the processing, the categories of personal data concerned and the recipients of the personal data. Providing the rights and freedoms of others are not affected, we will supply to you a copy of your personal data. The first copy will be provided free of charge, but additional copies may be subject to a reasonable fee.

7.4   You have the right to have any inaccurate personal data about you rectified and, taking into account the purposes of the processing, to have any incomplete personal data about you completed.

7.5    In some circumstances you have the right to the erasure of your personal data without undue delay. Those circumstances include: the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed; you withdraw consent to consent-based processing; you object to the processing under certain rules of applicable data protection law; the processing is for direct marketing purposes; and the personal data have been unlawfully processed. However, there are exclusions of the right to erasure. The general exclusions include where processing is necessary: for exercising the right of freedom of expression and information; for compliance with a legal obligation; or for the establishment, exercise or defence of legal claims.

7.6    In some circumstances you have the right to restrict the processing of your personal data. Those circumstances are: you contest the accuracy of the personal data; processing is unlawful but you oppose erasure; we no longer need the personal data for the purposes of our processing, but you require personal data for the establishment, exercise or defence of legal claims; and you have objected to processing, pending the verification of that objection. Where processing has been restricted on this basis, we may continue to store your personal data. However, we will only otherwise process it: with your consent; for the establishment, exercise or defence of legal claims; for the protection of the rights of another natural or legal person; or for reasons of important public interest.

7.7    You have the right to object to our processing of your personal data on grounds relating to your particular situation, but only to the extent that the legal basis for the processing is that the processing is necessary for: the performance of a task carried out in the public interest or in the exercise of any official authority vested in us; or the purposes of the legitimate interests pursued by us or by a third party. If you make such an objection, we will cease to process the personal information unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing is for the establishment, exercise or defence of legal claims.

7.8    You have the right to object to our processing of your personal data for direct marketing purposes (including profiling for direct marketing purposes). If you make such an objection, we will cease to process your personal data for this purpose.

7.9    To the extent that the legal basis for our processing of your personal data is:

(a)    consent; or  (b) that the processing is necessary for the performance of a contract to which you are party or in order to take steps at your request prior to entering into a contract, and such processing is carried out by automated means, you have the right to receive your personal data from us in a structured, commonly used and machine-readable format. However, this right does not apply where it would adversely affect the rights and freedoms of others.

7.10  If you consider that our processing of your personal information infringes data protection laws, you have a legal right to lodge a complaint with a supervisory authority responsible for data protection. You may do so in the EU member state of your habitual residence, your place of work or the place of the alleged infringement. In the UK the supervisory authority is the Information Commissioner’s Office (ICO).

7.11  To the extent that the legal basis for our processing of your personal information is consent, you have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing before the withdrawal.

7.12  You may exercise any of your rights in relation to your personal data by contacting us at the details shown at section 13.

  1. The rights of Survey Respondents  

8.1    The rights of individuals taking part in surveys administered via the Ceeda Survey System (“survey respondents”) are outlined here:

https://www.ceeda.co.uk/media/1239/ceeda-privacy-policy-for-ceeda-survey-respondents_employees_v1_21_5_18.pdf

https://www.ceeda.co.uk/media/1240/ceeda-privacy-policy-for-ceeda-survey-respondents_customers_v5_21_5_18.pdf

8.2        A copy of the relevant policy is made available when obtaining the informed consent of Survey Respondents at the point of data collection.

8.3        Survey Respondents can exercise their rights in respect of personal data submitted when taking part in surveys on the Ceeda Survey System, by contacting us on the details shown at section 13.

  1. About cookies

9.1    A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server.

9.2    Cookies may be either "persistent" cookies or "session" cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.

9.3    Cookies do not typically contain any information that personally identifies a user, but personal information that we store about you may be linked to the information stored in and obtained from cookies.

  1. Cookies that we use

10.1    We use cookies for the following purposes:

(a)    authentication - we use cookies to identify you when you visit our website and as you navigate our website (cookies used for this purpose are: identify cookies);

(b)    status - we use cookies to help us to determine if you are logged into our website (cookies used for this purpose are: identify cookies);

(c)   security - we use cookies as an element of the security measures used to protect user accounts, including preventing fraudulent use of login credentials, and to protect our website and services generally (cookies used for this purpose are: identify cookies);

(d)   analysis - we use cookies to help us to analyse the use and performance of our website and services (cookies used for this purpose are: identify cookies); and

(e)    cookie consent - we use cookies to store your preferences in relation to the use of cookies more generally (cookies used for this purpose are: identify cookies).

  1. Cookies used by our service providers

11.1  Our service providers use cookies and those cookies may be stored on your computer when you visit our website.

11.2  We use Google Analytics to analyse the use of our website. Google Analytics gathers information about website use by means of cookies. The information gathered relating to our website is used to create reports about the use of our website. Google's privacy policy is available at: https://www.google.com/policies/privacy/. The relevant cookies are: identify cookies.

  1. Managing cookies

12.1  Most browsers allow you to refuse to accept cookies and to delete cookies. The methods for doing so vary from browser to browser, and from version to version. You can however obtain up-to-date information about blocking and deleting cookies via these links:

(a)    https://support.google.com/chrome/answer/95647?hl=en (Chrome);

(b)    https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences (Firefox);

(c)    http://www.opera.com/help/tutorials/security/cookies/ (Opera);

(d)    https://support.microsoft.com/en-gb/help/17442/windows-internet-explorer-delete-manage-cookies (Internet Explorer);

(e)    https://support.apple.com/kb/PH21411 (Safari); and

(f)    https://privacy.microsoft.com/en-us/windows-10-microsoft-edge-and-privacy (Edge).

12.2  Blocking all cookies will have a negative impact upon the usability of many websites.

12.3  If you block cookies, you will not be able to use all the features on our website.

  1. Our details

13.1  www.aboutearlyyears.co.uk and www.ceeda.co.uk are websites owned and operated by Ceeda Research Limited.

13.2  We are registered in England and Wales under registration number 4709056. and our registered office is at 14 High Street, Yarm, Stockton on Tees, TS15 9AE.

13.3  Our principal place of business is at 14 High Street, Yarm, Stockton on Tees, TS15 9AE.

13.4  You can contact us:

(a)    by post, to the postal address given above;

(b)    using our website contact form;

(c)    by telephone, on 0845 680063; or

(d)    by email, to enquiries@ceeda.co.uk.

Contact details for the Information Commissioner’s Office (ICO) are available at: https://ico.org.uk/concerns/